Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 1183

Administrative Motion to File Under Seal Samsung's Claim Construction Brief filed by Samsung Electronics Co. Ltd.. (Attachments: #1 Trac Declaration in Support of Motion to Seal, #2 Proposed Order, #3 Samsung's Claim Construction Brief, #4 Schmidt Declaration in Support of Claim Construction Brief, #5 Exhibit 1, #6 Exhibit 2, #7 Exhibit 3, #8 Exhibit 4, #9 Exhibit 5, #10 Exhibit 6, #11 Exhibit 7, #12 Exhibit 8, #13 Exhibit 9, #14 Exhibit 10, #15 Exhibit 11, #16 Exhibit 12, #17 Exhibit 13, #18 Exhibit 14)(Maroulis, Victoria) (Filed on 7/5/2012)

EXHIBIT 8

99999.77769/4844798.1

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
APPLE INC., a California corporation,
Plaintiff,
vs.
SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,

CASE NO. 11-cv-01846-LHK

Defendants.

EXPERT REPORT OF STEPHEN GRAY
REGARDING INVALIDITY OF U.S. PATENT NOS. 7,844,915 AND 7,864,163

SUBJECT TO PROTECTIVE ORDER
CONTAINS HIGHLY CONFIDENTIAL – ATTORNEYS' EYES ONLY INFORMATION

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time. PDAs will get more power and smaller size and accommodate more, and
more versatile functionalities.
Bandwidth and display size are believed to be the factors that limit the
usability and practicality of the handheld device, be it a mobile phone, a palmtop
or a hybrid. In particular, the GUI and the services accessible to such handhelds
are critical factors for the consumers' acceptability of such services.
Van Ee US 2002/0030699 A1 at [0005-0006].
2.
273.

Touch Screen Displays

As discussed in Section III.A.2 multi-touch display technology was well known by

persons of ordinary skill in the art in 2006. The term "touch screen display" was commonly used
to refer to displays incorporating the well-known technologies for sensing the direct touch of a
user through resistive, optical and acoustic technologies.
3.
274.

Structured Electronic Documents
At the time of the '163 Patent, persons skilled in the art would have been familiar

with structured electronic documents and their various applications. As understood by those in the
art, a "structured electronic document" refers to any type of two dimensional information space
containing embedded coding that provides some meaning or "structure" to the document. The
coding is embedded within the content of the document and specifies how elements or objects are
to be arranged within the information space and relative to one another. Thus, the comingling of
data providing structure and data providing content in the code of the document is a distinguishing
t
feature of a structured electronic document.
275.

Two common markup languages known to persons skilled in the art at the time of

filing the '163 Patent were Hypertext Markup Language ("HTML") and Extensible Markup
Language ("XML"). HTML was and is the most common form of markup languages for the web
pages that comprise the World Wide Web. An HTML document consists of "tags" that are
embedded in, and surround, the content that is to be displayed. These tags provide the author's
intent as to how the elements are to be displayed and arranged on the HTML document presented
to a user through a standard web browser. The browser interprets these HTML tags and renders
the document on the two dimensional display surface accordingly.


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